CLA-2-73:OT:RR:NC:1:117
Mr. Peter Zhu
Amerjin Co., LLC.
7806 Richmond Ave., Ste. B
Houston, TX 77063
RE: The tariff classification of coupling stock from China.
Dear Mr. Zhu:
In your letter dated August 19, 2010 you requested a tariff classification ruling.
The product you plan to import is described as coupling stock. This seamless hot-rolled tubular steel product is used to manufacture pipe couplings. It will be imported in lengths ranging from 5 to 11 inches, outside diameters of 3.063 to 14.75 inches and wall thicknesses from .400 to .750 inches. This particular coupling stock meets API Specification 5CT, Grades K55, N80, P110 (all nonalloy steels) or L80-1 (either alloy or nonalloy steel depending on exact composition).
The API Grade L80-1 steel chemistry you submitted with your inquiry calls for a maximum of 1.9 percent manganese and a vanadium content of up to .45 percent. As per Chapter 72, Note 1(f), other alloy steel is a steel not complying with the definition of stainless and possibly containing one or more of certain elements in specified amounts. In order to be considered an alloy for tariff purposes, a steel must contain by weight 1.65 percent or more of manganese and/or 0.1 percent or more of vanadium. Therefore, Grade L80-1 steel with a manganese content of 1.65 percent or more and/or a vanadium content of 0.1 percent or more would be considered an other alloy steel.
The subject coupling stock is available in a variety of sizes and may have outside diameters which exceed their lengths. In those instances, these products cannot be considered pipes or tubes of Chapter 73.
The applicable subheading for the nonalloy coupling stock with a length greater than the outside diameter will be 7304.39.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other of circular cross section, of iron or nonalloy steel, other. The rate of duty will be free.
The applicable subheading for the L80-1 alloy coupling stock with a length greater than the outside diameter will be 7304.59, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other of circular cross section, of other alloy steel, other. The rate of duty will be free.
The applicable subheading for all coupling stock with an outside diameter greater than the length will be 7326.90.8588, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Mary Ellen Laker at (646) 733-3020.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division